Item 1 – Cover Page Monument Capital Management, LLC 1701 ...

Item 1 – Cover Page

Monument Capital Management, LLC 1701 Duke Street, Suite 425 Alexandria, Virginia 22314

(703) 504-9600 www.monumentwealthmanagement.com

Date of ADV Part 2A Brochure: July 14, 2021

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This brochure provides information about the qualifications and business practices of Monument Capital Management, LLC (“Monument Capital Management”). If you have any questions about the contents of this brochure, please contact David B. Armstrong, CFA at (703) 504-9600 or at [email protected]. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Monument Capital Management is also available on the Internet at www.adviserinfo.sec.gov. You can view our firm’s information on this website by searching for Monument Capital Management, LLC or our firm’s CRD number 159882. *Registration as an investment advisor does not imply a certain level of skill or training.

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Item 2 – Material Changes

Since the most recent Annual Amendment filing on March 22, 2020, this Brochure has not been materially amended.

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Item 3 – Table of Contents

Item 1 – Cover Page ..................................................................................................................................................................................... 1 Item 2 – Material Changes ........................................................................................................................................................................... 2 Item 3 – Table of Contents .......................................................................................................................................................................... 3 Item 4 – Advisory Business .......................................................................................................................................................................... 4

Ownership ................................................................................................................................................................................................ 4 General Description of Primary Advisory Services ............................................................................................................................. 4 Client Assets Managed by Monument Capital Management .......................................................................................................... 10

Item 5 – Fees and Compensation ............................................................................................................................................................. 10 Asset Management Services ................................................................................................................................................................ 10 Financial Planning and Consulting Services ....................................................................................................................................... 12 Additional Information Regarding Fees ............................................................................................................................................. 14

Item 6 – Performance-Based Fees and Side-By-Side Management ..................................................................................................... 14 Item 7 – Types of Clients ............................................................................................................................................................................ 15 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................................... 15

Methods of Analysis .............................................................................................................................................................................. 15 Investment Strategies ........................................................................................................................................................................... 16 Recommendation to Use a Specific Type of Security ....................................................................................................................... 17 Risk of Loss ............................................................................................................................................................................................ 17

Item 9 – Disciplinary Information ............................................................................................................................................................. 20 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................................................... 21 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ....................................................................... 21 Item 12 – Brokerage Practices .................................................................................................................................................................. 22

Best Execution ....................................................................................................................................................................................... 23 Handling Trade Errors .......................................................................................................................................................................... 23 Block Trading Policy .............................................................................................................................................................................. 24

Item 13 – Review of Accounts ................................................................................................................................................................... 24 Account Reviews and Reviewers ......................................................................................................................................................... 24 Statements and Reports ....................................................................................................................................................................... 24

Item 14 – Client Referrals and Other Compensation ............................................................................................................................. 24 Item 15 – Custody ....................................................................................................................................................................................... 25 Item 16 – Investment Discretion .............................................................................................................................................................. 25 Item 17 – Voting Client Securities ............................................................................................................................................................. 25 Item 18 – Financial Information ................................................................................................................................................................ 26 Customer Privacy Policy Notice ................................................................................................................................................................ 27 Class Action Lawsuits ................................................................................................................................................................................. 28 Business Continuity Plan ........................................................................................................................................................................... 29

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Item 4 – Advisory Business

Ownership Monument Capital Management (“we”, “our”, the “Firm”) is an investment advisor registered with the Securities and Exchange Commission since June 2012. We are a limited liability company formed under the laws of the state of Delaware. David Armstrong and Dean Catino are equal owners of the firm.

General Description of Primary Advisory Services

The following are brief descriptions of Monument Capital Management’s primary services. A detailed description of our services is provided in Item 5 – Fees and Compensation so that clients and prospective clients (“clients” or “you”) can review the description of services and description of fees in a side-by-side manner. We offer several investment programs designed to help our clients meet their specific goals and investment objectives, descriptions of each program can be found in Item 5 – Fees and Compensation, below. Monument Capital Management Asset Management Services. We offer asset management services that involve providing you with continuous and on-going supervision over your accounts. The Account is managed by Monument Capital Management based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account and make trades in your accounts when necessary.

When you engage Monument Capital Management, you appoint Monument Capital Management as your investment advisor of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. Qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account.

Financial Planning and Consulting Services. We offer financial planning services that can include preparation of a financial plan covering specific or multiple topics. Monument Capital Management provides financial plans typically addressing the following topics: investment planning, retirement planning, insurance planning, tax planning, education planning, portfolio reviews, asset allocation, real estate planning and estate planning. Under this program, the role of your investment advisor representative as a financial planner is to find ways to help you understand your overall financial situation and help you set financial objectives. Monument Capital Management also provides modular financial plans which only cover those specific areas of concern mutually agreed between us. A modular (segmented) financial plan is limited and does not involve the creation of a full financial plan. You should be aware that other important issues may not be taken into consideration when your investment advisor representative develops his analysis and recommendations under a modular

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financial plan. Financial plans prepared by Monument Capital Management may include specific recommendations of individual securities.

Monument Capital Management also provides consultations in order to discuss financial planning issues when you do not need a full financial plan. Monument Capital Management offers a one-time consultation, which covers mutually agreed upon areas of concern related to investments or financial planning. Monument Capital Management also offers “as-needed” consultations which are limited to consultations with us in response to a particular investment or financial planning issue raised or a request made by you. Under an “as-needed” consultation, you identify those particular issues needing our advice or consultation.

To begin the process for either a full or modular (segmented) plan, our representatives meet with you to gather information and documentation needed to perform an analysis and review of your situation as well your objectives and goals. One or more meetings may be required in order to gather all needed information and determine the services best suited to help meet your needs. We rely on the information provided by you. Therefore, it is very important that the information you provide is complete and accurate. We are not responsible for verifying the information you supply. Our services do not include legal or tax advice. You are urged to work closely with your attorney, accountant or other professionals regarding your financial and personal situation.

If requested by the client, Monument Capital Management may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Monument Capital Management.

If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not Monument Capital Management, shall be responsible for the quality and competency of the services provided.

It remains the client’s responsibility to promptly notify Monument Capital Management if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising our previous recommendations and/or services.

Monument Capital Management Wrap Program Monument Capital Management provides investment management services on a wrap fee basis in accordance with its investment management wrap fee program (the “Program”). The services offered under, and the corresponding terms and conditions pertaining to, the Program are discussed in the Wrap Fee Program Brochure a copy of which is presented to all prospective Program participants. Under the Program, Monument Capital Management is able to offer participants discretionary investment management services, for a single specified annual Program fee, inclusive of trade execution, custody, reporting, and investment management fees. The terms and conditions for client

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participation in the Program are set forth in detail in the Wrap Fee Program Brochure. All prospective Program participants should read our Wrap Fee Brochure, and ask any corresponding questions that they may have, prior to participation in the Program. TD Ameritrade Institutional, Division of TD Ameritrade Inc., member FINRA/SIPC (“Ameritrade”) generally serves as the custodian for Program accounts. Wrap Program-Conflict of Interest. Under Monument Capital Management’s wrap program, the client receives investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the client more or less than purchasing such services separately. The terms and conditions of a wrap program engagement are more fully discussed in Monument Wealth Management’s Wrap Fee Program Brochure. Monument Capital Management has entered into an Asset Based Pricing (“APB”) arrangement with TD Ameritrade Institutional which covers all program transaction fees, including ticket charges, commissions, and other charges for trading and custody. Because TD Ameritrade Institutional’s ABP fee is based on a percentage of the value of all program assets other than assets invested or held in cash, money market funds, non-transaction fee mutual funds, and commission-free exchange traded funds (collectively the “Non-ABP-Funds”), a conflict of interest exists as Monument Capital Management has an economic incentive to allocate or re-allocate program clients assets into Non-ABP-Funds to reduce Monument Capital Management’s overall costs under the ABP arrangement.

Miscellaneous

Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a client, Monument Capital Management may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. for a separate and additional fee per the terms and conditions of a Financial Planning and Consulting Agreement. Neither Monument Capital Management nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. Monument Capital Management does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with Monument Capital Management, if desired. Monument Capital Management does not serve as an attorney or accountant, and no portion of our services should be construed otherwise. Accordingly, Monument Capital Management does not prepare estate planning documents or tax returns. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purpose (i.e. attorneys, accountants, insurance, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Monument Capital Management and/or its representatives.

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If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not Monument Capital Management, shall be responsible for the quality and competency of the services provided. Structured Notes. Monument Capital Management may purchase structured notes as part of the MWM Structured Notes Portfolio offered to clients. A structured note is generally a financial instrument that combines two elements, a debt security and exposure to an underlying asset or assets. However, the MWM Structured Notes Portfolio may also contain structured notes that do not contain a debt security. A structured note is essentially a promissory note, carrying counter party risk of the issuer. However, the return on the note is linked to the return of an underlying asset or assets (such as the S&P 500 Index or commodities). It is this latter feature that makes structured products unique, as the payout can be used to provide some degree of principal protection, leveraged returns (but usually with some cap on the maximum return), and be tailored to a specific market or economic view. In addition, investors may receive long-term capital gains tax treatment if certain underlying conditions are met and the note is held for more than one year. There can be no assurance that any such product will prove profitable or successful. In light of the enhanced risks/rewards, a client may direct Monument Capital Management, in writing, not to direct any portion of their investing portfolio into the MWM Structured Notes Portfolio. Unaffiliated Private Investment Funds. Monument Capital Management may recommend that certain qualified clients consider an investment in unaffiliated private investment funds. Monument Capital Management’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. Clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Risks: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Valuation: If Monument Capital Management bills an investment advisory fee based upon the value of private investment funds or otherwise references private investment funds owned by the client on any supplemental account reports prepared by Monument Capital Management, the value for all private investment funds owned by the client will reflect the most recent valuation provided by the fund sponsor. The current value of any private investment fund could be significantly more or less than the original purchase price or the price reflected in any supplemental account report.

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Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Monument Capital Management recommends that a client roll over their retirement plan assets into an account to be managed by Monument Capital Management, such a recommendation creates a conflict of interest if Monument Capital Management will earn an advisory fee on the rolled over assets. No client is under any obligation to roll over retirement plan assets to an account managed by Monument Capital Management. Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are available directly to the public. Therefore, a prospective client can obtain many of the funds that may be utilized by Monument Capital Management independent of engaging Monument Capital Management as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Monument Capital Management’s initial and ongoing investment advisory services. Independent Managers. Monument Capital Management may recommend that the client allocate a portion of a client’s investment assets among unaffiliated independent investment managers (“Independent Manager(s)”) in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) will have day-to-day responsibility for the active discretionary management of the allocated assets. Monument Capital Management will continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation, and client investment objectives. Monument Capital Management generally considers the following factors when recommending Independent Manager(s): the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Manager(s) are exclusive of, and in addition to, Monument Capital Management’s ongoing investment advisory fee, subject to the terms and conditions of a separate agreement between the client and the Independent Manager(s). Monument Capital Management’s advisory fee is set forth in the fee schedule at Item 5 below. eMoney Advisor Platform and Orion Advisor Services. Monument Capital Management may provide its clients with access to online platforms hosted by “eMoney Advisor” (“eMoney”) and Orion Advisor Services (“Orion”). The eMoney platform and Orion, through its use of Quovo, allow clients to view their complete asset allocation, including those assets that Monument Capital Management does not manage (the “Excluded Assets”). Monument Capital Management does not provide investment management, monitoring, or implementation services for the Excluded Assets. Therefore, Monument Capital Management shall not be responsible for the investment performance of the Excluded Assets. Rather, the client and/or their advisor(s) that maintain management authority for the Excluded Assets, and not Monument Capital Management, shall be exclusively responsible for such investment performance. The client may choose to engage Monument Capital Management to manage some or

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all of the Excluded Assets pursuant to the terms and conditions of an Investment Advisory Agreement between Monument Capital Management and the client. Cash Positions. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Monument Capital Management maintains cash positions for defensive purposes. All cash positions (money markets, etc) shall be included as part of assets under management and subject to the same fee schedule as non-cash assets for purposes of calculating Monument Capital Management’s advisory fee. Portfolio Activity. Monument Capital Management has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Monument Capital Management will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Monument Capital Management determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Client Obligations. In performing its services, Monument Capital Management shall not be required to verify any information received from the client or from the client’s other designated professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Monument Capital Management if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Monument Capital Management’s previous recommendations and/or services. Disclosure Statement. Copies of our written Brochure and Client Relationship Summary, as set forth on Part 2A of Form ADV and Form CRS respectively, shall be provided to each client prior to, or contemporaneously with, the execution of an Advisory or Financial Planning Agreement. When providing asset management services, Monument Capital Management typically constructs each client’s account holdings using ETFs, mutual funds and individual equities to build diversified portfolios. We do not typically attempt to time the market but we may increase cash holdings modestly, as deemed appropriate, based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles or special tax situations. Please refer to Item 8, Methods of Analysis, Investment Strategies and Risk of Loss for more information. Monument Capital Management’s services are provided based on the individual needs of each client. This means, for example, that clients are given the ability to impose restrictions on the accounts we manage for them, including specific investment selections and sectors. We work with each client on

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a one-on-one basis through interviews and questionnaires to determine their investment objectives and suitability information. However, we reserve the right to not enter into an investment advisor relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines.

Client Assets Managed by Monument Capital Management

As of March 18, 2021 Monument Capital Management had $353,702,263 in assets under management on a discretionary basis and $7,218,414 in assets under management on a non-discretionary basis.

Item 5 – Fees and Compensation

In addition to the information provided in Item 4 – Advisory Business, this section provides additional details regarding our firm’s services along with descriptions of each services’ fees and compensation arrangements.

Asset Management Services

We are the sponsor of the Monument Capital Management Wrap Program (“Monument Capital Management Program”). Through the Monument Capital Management Program, we provide investment management services, including providing continuous investment advice to and making investments for you based on your goals and investment objectives. Through this service, we offer several investment programs designed to help our clients meet their specific goals and investment objectives. Monument Capital Management Program accounts are generally custodied at Ameritrade. Ameritrade provides clearing, custody and other brokerage services for accounts established through the Monument Capital Management Program. Therefore, you are generally required to establish a brokerage account(s) through Ameritrade. Separate accounts are maintained for you, and you retain all rights of ownership of your accounts (e. g., the right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). The Monument Capital Management Program accounts allow you to authorize us to purchase and sell, on a discretionary basis only, portfolios consisting of securities and investments. We may limit our discretion with respect to your account and the securities eligible to be purchased for your account. See Item 16 - Investment Discretion for information concerning discretionary authority. Under the Monument Capital Management Program, we are able to offer participants discretionary investment management services, for a negotiable single specified annual Program fee, inclusive of trade execution, custody, reporting, and investment management fees.

The current annual Program fee is negotiable and generally ranges up to a maximum annual fee of 1.75% of assets under management. Each client’s investment management fee shall be based upon

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various objective and subjective factors, including, but not limited to: the amount and composition of the assets placed under Monument Capital Management’s management, the complexity of the engagement, the potential for additional deposits, your relationship and history with Monument Capital Management, and the level and scope of the overall investment advisory services to be rendered.

As a result of these factors, Monument Capital Management’s investment management fee may be higher or lower than other similarly situated client. Therefore, the services to be provided by Monument Capital Management to any particular client could be available from other advisers at lower fees. All clients and prospective clients should be guided accordingly.

In certain limited circumstances, Monument Capital Management may, in its sole discretion, offer its services on a fixed annual fee basis.

The annual fee is prorated and paid quarterly in advance through a direct debit to your account. For those accounts maintained with Ameritrade, we utilize Orion to calculate fees. Orion calculations are provided to Ameritrade and Ameritrade debits our fees from your account with your written authorization. Advisory fees debited from Ameritrade are paid directly to us. Fees are generally based on the account's asset value as of the last business day of the prior calendar quarter.* Fees for accounts opened at any time other than the beginning of a quarter are prorated based on the number of days remaining in the initial quarter. Additional deposits and withdrawals will be added or subtracted from portfolio assets on a prorated basis to adjust the Account Fee. * Fee calculation performed through Orion shall rely upon Orion’s method for determining account values, which includes accrured interest on bond positions. As a result, these client accounts may be valued for billing purposes higher or lower than as reflected in quarterly account statements provided by Ameritrade. A higher account valuation will result in a larger fee due to Monument Capital Management. Higher fees adversely effect investment returns. Prior to engaging us to provide investment management services, you are required to enter into a formal investment advisory agreement with us setting forth the terms and conditions, including the amount of investment advisory fees, under which we manage your assets and also a separate custodial/clearing agreement with Ameritrade.

The Monument Capital Management Program account is a wrap fee account, meaning you do not pay transaction charges associated with trade execution. The Monument Capital Management Program may cost you more or less than if the assets were held in a traditional brokerage account. Beginning in January 2020, your account custodian, TD Ameritrade, stopped charging transaction fees for individual equities (i.e., common stocks and ETFs). As the result of TD’s decision, total transaction fees paid by Monument Capital Management under the Monument Capital Management wrap program decreased. Monument Capital Management did not alter its advisory fee schedule as result of this change.

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Either party may terminate the agreement for services at any time by providing written notice to the other party. Termination is effective immediately upon receipt of the termination notice. Fees are prorated based on the number of days that services were actually provided during the final quarter and any prepaid, unearned fees are promptly refunded to you. General Description of Our Programs

MWM Global Macro Opportunities ETF Portfolio – (ETF Portfolio) - Tax efficient and globally diversified portfolio comprised entirely of exchange traded funds (ETFs). We conduct macro-economic analysis to select ten (10) to fifteen (15) ETFs that provide exposure to selected equity indices, sectors and asset classes.

MWM Dividend Portfolio - A concentrated individual stock portfolio designed to provide returns driven by dividend income and growth by purchasing individual securities that have an acceptable current yield and a history of dividend safety and growth. We identify twenty (20) stocks with a history of increasing dividends. MWM Strategic Growth Portfolio - A concentrated individual stock portfolio designed to provide high equity growth returns. We collect data from a variety of research providers to identify twenty (20) companies with increasing earnings estimates that we anticipate will reflect high growth.

MWM Structured Notes Portfolio – a portfolio designed to invest in structured notes issued by credit worthy institutions that focus on maturity dates between 12-18 months, track two indices and provide some level of downside protection in exchange for a set coupon amount at maturity.

MWM Strategic Income Portfolio – a concentrated portfolio designed to invest in mutual funds, ETFs, and Business Development Companies which provide exposure to managers and sectors that represent certain investment themes determined by the investment management committee.

MWM Tax Rebalanced Index Optimized (TRIO) portfolio – a portfolio comprised of both individual securities and ETFs that is optimized through software to create low tracking error relative to the benchmarked indices while maintaining the ability to harvest tax losses as available.

Financial Planning and Consulting Services

Financial Plans

Financial planning fees are charged on a fixed fee basis. Fees are disclosed prior to any services being provided. Clients typically pay the full financial planning fee in advance of the service being provided.

Fixed fees generally range from $2,500 to $25,000 and are negotiable based on the actual services provided, the representative providing the services, the complexity of your situation, other advisory services provided and your history and relationship with us. We quote the fee to you before services are provided and fees are due at the time the client agreement is signed.

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We do not charge more than $1,200 more than six months in advance, so the requested plan will be provided to you within six months from signing the agreement as long as all required information has been provided to us.

If you contract for a full plan, you receive ongoing financial planning services for a one-year period at no additional charge. These services include consultations, reviews and updates regarding any topic included in the original plan. Our Financial planning services are renewable on an annual basis. Prior to the completion of your annual financial planning term, Monument Capital Management offers clients the opportunity to renew the engagement for another year.

Either party can terminate any financial planning services at any time by providing written notice to the other party. Termination is effective immediately. If services are terminated prior to the plan being presented, you receive a full refund of all prepaid fees. If ongoing services are terminated after the plan has been presented, there is no refund since the ongoing services are provided at no additional charge. Limited and Advisement Consultations

If you do not need a financial plan, you may contract with us for limited consultation services. These consultations can cover any topics or areas of interest or concern to you and can be a single event or involve multiple meetings.

Consultation fees can be charged as a fixed fee as determined jointly by you and us, and fees are disclosed prior to any services being provided.

Fixed fees generally range from $2,500 to $25,000 and are negotiable based upon the actual services provided, the representative providing the services, the complexity of your situation, other advisory services provided and your history and relationship with us. For multiple consultations charged as a fixed fee, we may require a retainer of 50% of the previously quoted fixed fee to be paid at the time the client agreement is signed. The balance of the fee is due upon completion of the consultations and receipt of our billing statement.

Monument Capital Management also offers advisement consultations to participants in benefit plans (401(k) plans, profit sharing plans, etc.). Advisement consultations can be provided as a one-time service or as an on-going service (one-year). When providing these services, we review your financial situation, goals and objectives as well as the investment options available in the benefit plan. Although we do not make judgments on the quality or value of the specific investment choices available to you, we do make recommendations regarding asset allocation and investment selections for the investment portfolio in the plan.

Advisement services are charged at the same hourly and fixed fee rates as described above for limited consultations. At our sole discretion, and based upon the actual services provided and your relationship to the firm, we may waive our fees for a one-time advisement consultation.

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One-time consulting services automatically terminate upon completion of the consultation. Either party may also terminate consulting services by providing written notice to the other, and termination is effective immediately. In the event that consultation services are terminated, there are no fees or penalties due and any prepaid fees are promptly refunded.

Additional Information Regarding Fees

General Information Regarding Fees

As discussed below, unless the client directs otherwise or an individual client’s circumstances require, Monument Capital Management shall generally recommend that Ameritrade serve as the custodian for client investment management assets. Custodians such Ameritrade charge brokerage commissions and/or transaction fees for effecting certain securities transactions. Advisory clients who choose to engage Monument Capital Management on a wrap-fee basis will not incur these fees in addition to Monument Capital Management's wrap-fee. However, in addition to Monument Capital Management’s investment management fee, all clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Furthermore, to the extent any client maintains an IRA or an account holding alternative investments with Ameritrade, certain additional account fees may apply (e.g. annual alternative investment fee) which shall be incurred by the client, whether Monument Capital Management has been engaged on a wrap or non-wrap fee basis, separate and apart from Monument Capital Management’s investment management fee. Accommodation Account Fees Clients may request that Monument Capital Management maintain accounts on their behalf on an accommodation basis. Monument Capital Management shall not be responsible for the management of these accounts. Instead, the client and/or their other advisors that maintain trading authority, and not Monument Capital Management, shall be exclusively responsible for the investment performance of the Excluded Assets. However, Monument Capital Management shall impose a nominal annual fee of eight basis points (0.08%), payable quarterly in advance based upon the value of the accommodation account as of the last day of the previous quarter, on any such accommodation accounts maintained by the client at Ameritrade.

Item 6 – Performance-Based Fees and Side-By-Side Management

Performance-based fees are fees based on a share of capital gains or capital appreciation of the assets held within a client’s account. We do not charge or accept performance-based fees.

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Item 7 – Types of Clients

Monument Capital Management’s clients shall generally include individuals, high net worth individuals, trusts, and estates. We do not generally require an annual minimum fee or an aggregate minimum account value for our investment advisory services. Monument Capital Management, in its sole discretion, may charge a lesser investment management fee based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, negotiations with client, etc.). As result of the above, similarly situated clients could pay different fees. In addition, similar advisory services may be available from other investment advisers for similar or lower fees.

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

Methods of Analysis Monument Capital Management may use charting, cyclical, fundamental and technical analysis when considering investment strategies and recommendations for clients. Our primary method of investment strategy and analysis is fundamental.

Fundamental. This is a method of evaluating a security by attempting to measure its intrinsic value by examining related economic, financial and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security's value, including macroeconomic factors (like the overall economy and industry conditions) and individually specific factors (like the financial condition and management of companies). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price in hopes of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short).

Charting. Charting is a technical analysis that charts the patterns of stocks, bonds and commodities to help determine buy and sell recommendations for clients. It is a way of gathering and processing price and volume information in a security by applying mathematical equations and plotting the resulting data onto graphs in order to predict future price movements. A graphical historical record assists the analyst in spotting the effect of key events on a security’s price, its performance over a period of time and whether it is trading near its high, near its low or in between. Chartists believe that recurring patterns of trading, commonly referred to as indicators, can help them forecast future price movements.

Cyclical. Cyclical analysis looks at recurring periods of expansion and contraction that can impact a company’s profitability and cash flow. Cyclical stocks tend to rise quickly when the economy turns up and fall quickly when the economy turns down (i.e., housing, automobiles, telecommunications, paper, etc.). Non-cyclical industries (i.e., food, insurance, drugs, health care, etc.) are not as directly impacted by economic changes.

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Technical. This is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. Technical analysts believe that the historical performance of stocks and markets are indications of future performance.

There are risks involved in using any analysis method. Fundamental analysis takes a long-term approach to analyzing markets, often looking at data over a number of years. The data reviewed is released over years (e.g., quarterly financial statements). Technical analysis uses a shorter timeframe—often weeks or days. The price and volume data reviewed is released on a daily basis. Therefore, fundamental analysis could mean a gain is not realized until a security’s market price rises to its “correct” value over the long run--perhaps several years. As a general statement, technical analysis is used for a trade while fundamental analysis is used for an investment. It could also be said that traders buy assets they believe they can sell to someone else at a greater price while investors buy assets they believe will increase in value. The frequency of trading securities using technical analysis could have both a positive or negative impact and could also lead to increased brokerage and transaction costs, thus lowering performance. The less frequent trading practices of fundamental analysis could also have a positive or negative impact on a client’s portfolio value, but likely has reduced brokerage and transaction costs. Cyclical analysts look for patterns to help identify the direction the market is going at any given time. However, patterns and expected ranges or time frames may not occur as anticipated due to any number of factors (i.e., natural disasters, political upheaval, etc.). This could also be true of charting analysis. To conduct analysis, Monument Capital Management gathers information from financial newspapers and magazines, inspection of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses and filings with the SEC and company press releases.

Investment Strategies Monument Capital Management uses the following investment strategies when managing client assets and/or providing investment advice:

• Long term purchases. Investments held at least a year • Short term purchases. Investments sold within a year. • Trading. Investments sold within 30 days.

Monument Capital Management’s methods of analysis and investment strategies do not present any significant or unusual risks.

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However, every method of analysis has its own inherent risks. To perform an accurate market analysis Monument Capital Management must have access to current/new market information. Monument Capital Management has no control over the dissemination rate of market information; therefore, unbeknownst to Monument Capital Management, certain analyses may be compiled with outdated market information, severely limiting the value of Monument Capital Management’s analysis. Furthermore, an accurate market analysis can only produce a forecast of the direction of market values. There can be no assurances that a forecasted change in market value will materialize into actionable and/or profitable investment opportunities. Monument Capital Management’s primary investment strategies - Long Term Purchases, Short Term Purchases, and Trading - are fundamental investment strategies. However, every investment strategy has its own inherent risks and limitations. For example, longer term investment strategies require a longer investment time period to allow for the strategy to potentially develop. Shorter term investment strategies require a shorter investment time period to potentially develop but, as a result of more frequent trading, may incur higher transactional costs when compared to a longer term investment strategy. Trading, an investment strategy that requires the purchase and sale of securities within a thirty (30) day investment time period, involves a very short investment time period but will incur higher transaction costs when compared to a short term investment strategy and substantially higher transaction costs than a longer term investment strategy.

Recommendation to Use a Specific Type of Security

Monument Capital Management recommends ETFs for client investments. In simple terms, ETFs are funds that hold all the securities in an index (e.g., the U.S. Dow) and trade like a stock. In an ETF, the manager’s job is to keep the portfolio as close to its index as possible rather than to make judgments on a single security. To keep the portfolio aligned with its index, the manager must buy the stock in the index regardless of the security’s price. There are also risks associated with ETFs:

• Geographical Limitations: The United States has many ETF products but some countries have only a few ETFs available with limited products (e.g., only large-cap products).

• Trading Limitations: If ETFs have large trading volumes, the advantage of purchasing it over an index or equity diminishes. In addition, active ETFs can increase trading fees and expenses.

• Investment Horizon Limitation: The trading opportunities of an ETF may be more suitable for a short-term investor than a long-term investor.

• Inactivity Limitation: Some ETFs are not as actively traded as others and investing in actively managed mutual fund may be more effective.

• Tax Limitations: Tax laws vary from state to state and country to country. For foreign investments, it may be more advantageous to find another product.

Securities Based Loans. Monument Capital Management does not generally recommend the use of margin loans or securities based loans (collectively, “SBLs”) as an investment strategy, in which the client would leverage borrowed assets as collateral for the purchase of additional securities. However, Monument Capital Management may recommend that a client establish a margin account with the

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client’s broker-dealer/custodian or their affiliated banks (each, an “SBL Lender”) to access SBLs for financial planning and cash flow management purposes. For example, we may deem it advisable for a client to borrow money on margin to pay bills or other expenses such as financing the purchase, construction, or maintenance of a real estate project. Monument Capital Management does not receive any compensation in connection with a client’s use of any SBLs.

The terms and conditions of each SBL are contained in a separate agreement between the client and the SBL Lender selected by the client, which terms and conditions may vary from client to client. Borrowing funds on margin is not suitable for all clients and is subject to certain risks, including but not limited to: increased market risk, increased risk of loss, especially in the event of a significant downturn; liquidity risk; the potential obligation to post collateral or repay the SBL if the SBL Lender determines that the value of collateralized securities is no longer sufficient to support the value of the SBL; the risk that the SBL Lender may liquidate the client’s securities to satisfy its demand for additional collateral or repayment / the risk that the SBL Lender may terminate the SBL at any time. Before agreeing to participate in an SBL program, clients should carefully review the applicable SBL agreement and all risk disclosures provided by the SBL Lender including the initial margin and maintenance requirements for the specific program in which the client enrolls, and the procedures for issuing “margin calls” and liquidating securities and other assets in the client’s accounts.

Risk of Loss

Past performance is not indicative of future results. Therefore, you should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, ETFs and bonds) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal.

Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks associated when investing in securities through our investment management program.

• Market Risk – Either the stock market as a whole, or the value of an individual company, goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk.

• Equity (stock) market risk – Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer.

• Company Risk. When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate

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diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced.

• Fixed Income Risk. When investing in bonds, there is the risk that issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk.

• Options Risk. Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks.

• ETF and Mutual Fund Risk – When investing in a an ETF or mutual fund, you may bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. Clients may also incur brokerage costs when purchasing ETFs.

• Management Risk – Your investment with our firm varies with the success and failure of our investment strategies, research, analysis and determination of portfolio securities. If our investment strategies do not produce the expected returns, the value of the investment will decrease.

• REITs - REITs are subject to risks generally associated with investing in real estate, such as: possible declines in the value of real estate; adverse general and local economic conditions; possible lack of availability of mortgage funds; changes in interest rates; and environmental problems. In addition, REITs are subject to certain other risks related specifically to their structure and focus such as: dependency upon management skills; limited diversification; the risks of locating and managing financing for projects; heavy cash flow dependency; possible default by borrowers; the costs and potential losses of self-liquidation of one or more holdings; the possibility of failing to maintain exemptions from securities registration; and, in many cases, relatively small market capitalization, which may result in less market liquidity and greater price volatility.

Monument Capital Management may also allocate investment management assets of its client accounts, on a discretionary basis, among one or more of its asset allocation models described below. Monument Capital Management’s asset allocation model administration has been designed to comply with the requirements of Rule 3a-4 of the Investment Company Act of 1940. Rule 3a-4 provides similarly managed investment programs with a non-exclusive safe harbor from the definition of an investment company. In accordance with Rule 3a-4, the following disclosure is applicable to Monument Capital Management’s management of client assets asset allocation models:

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1. Initial Interview – at the opening of the account, Monument Capital Management, through its designated representatives, shall obtain from the client information sufficient to determine the client’s financial situation and investment objectives; 2. Individual Treatment - the account is managed on the basis of the client’s financial situation and investment objectives; 3. Quarterly Notice – at least quarterly Monument Capital Management shall notify the client to advise Monument Capital Management whether the client’s financial situation or investment objectives have changed, or if the client wants to impose and/or modify any reasonable restrictions on the management of the account; 4. Annual Contact – at least annually, Monument Capital Management shall contact the client to determine whether the client’s financial situation or investment objectives have changed, or if the client wants to impose and/or modify any reasonable restrictions on the management of the account; 5. Consultation Available – Monument Capital Management shall be reasonably available to consult with the client relative to the status of the account; 6. Quarterly Report – the client shall be provided with a quarterly report for the account for the preceding period; 7. Ability to Impose Restrictions – the client shall have the ability to impose reasonable restrictions on the management of the account, including the ability to instruct Monument Capital Management not to purchase certain securities; 8. No Pooling – the client’s beneficial interest in a security does not represent an undivided interest in all the securities held by the custodian, but rather represents a direct and beneficial interest in the securities which comprise the account; 9. Separate Account - a separate account is maintained for the client with the Custodian; 10. Ownership – each client retains indicia of ownership of the account (e.g. right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). Monument Capital Management believes that its annual investment management fee is reasonable in relation to: (1) the advisory services provided under the Investment Advisory Agreement; and (2) the fees charged by other investment advisers offering similar services/programs. However, Monument Capital Management’s annual investment advisory fee may be higher than that charged by other investment advisers offering similar services/programs. In addition to Monument Capital Management’s annual investment management fee, the client will also incur charges imposed directly at the mutual and exchange traded fund level (e.g., management fees and other fund expenses). Monument Capital Management’s investment programs may involve above-average portfolio turnover which could negatively impact upon the net after-tax gain experienced by an individual client in a taxable account.

Item 9 – Disciplinary Information

There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our business or integrity.

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Item 10 – Other Financial Industry Activities and Affiliations

Monument Capital Management is an independent registered investment registered advisor and only provides investment advisory services. We are not engaged in any other business activities and offer no other services except those described in this Disclosure Brochure. However, while we do not sell products or services other than investment advice, our representatives may sell other products or provide services outside of their role as investment advisor representatives with us.

Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading

Monument Capital Management maintains an investment policy relative to personal securities transactions. This investment policy is part of our overall Code of Ethics, which serves to establish a standard of business conduct for all of our representatives that is based upon fundamental principles of openness, integrity, honesty and trust, a copy of which is available upon request.

In accordance with Section 204A of the Investment Advisers Act of 1940, Monument Capital Management also maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by Monument Capital Management or any person associated with us. Neither we nor any related person of Monument Capital Management recommends, buys, or sells for client accounts, securities in which Monument Capital Management or any related person of Monument Capital Management has a material financial interest. Monument Capital Management and/or our representatives may buy or sell securities that are also recommended to clients. This practice may create a situation where we and/or our representatives are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a potential conflict of interest. Practices such as “scalping” (i.e., a practice whereby the owner of shares of a security recommends that security for investment and then immediately sells it at a profit upon the rise in the market price which follows the recommendation) could take place if Monument Capital Management did not have adequate policies in place to detect such activities. In addition, this requirement can help detect insider trading, “front-running” (i.e., personal trades executed prior to those of our clients) and other potentially abusive practices. Monument Capital Management has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of each of our “Access Persons.” Our securities transaction policy requires that an Access Person of Monument Capital Management must provide the Chief Compliance Officer or his/her designee with a written report of their current securities holdings within ten (10) days after becoming an Access Person. Additionally, each Access Person must provide the Chief Compliance Officer or his/her designee with a written report quarterly, addressing any changes in the Access Person’s holdings from the previous quarter, and annually, detailing Access Person’s current securities holdings, thereafter on a date Monument Capital Management selects; provided, however that at any time that Monument Capital Management has only one Access Person, he or she shall not be required to submit any securities report described above.

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Monument Capital Management and/or our representatives may buy or sell securities, at or around the same time as those securities are recommended to clients. This practice creates a situation where Monument Capital Management and/or our representatives are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a potential conflict of interest. As indicated above in Item 11.C, Monument Capital Management has a personal securities transaction policy in place to monitor the personal securities transaction and securities holdings of each of our Access Persons.

Item 12 – Brokerage Practices

If you wish to implement our advice yourself, you are free to select any broker you wish. If you wish to implement our advice through any of the programs described in this Disclosure Brochure, Ameritrade will generally be used as the custodian. We recommend custodians that we feel provide services in a manner and at a cost that will allow us to meet our duty of best execution. While there is no direct linkage between the investment advice given to you and our recommendation of Ameritrade, economic benefits are provided to us by Ameritrade that are not provided if you select another account custodian. These benefits may include:

• Negotiated costs for transaction implementation • Access to a real-time order matching system • Electronic download of trades, balances and position information • Access, for a fee, to an electronic interface with the account custodian’s software • Duplicate and batched client statements, confirmations and year-end reports

TD Ameritrade’s Institutional Customer Program Monument Capital Management participates in Ameritrade’s institutional customer program and Monument Capital Management may recommend Ameritrade to clients for custody and brokerage services. There is no direct link between Monument Capital Management’s participation in the program and the investment advice it gives to its clients, although Monument Capital Management receives economic benefits through its participation in the program that are typically not available to Ameritrade retail investors. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving Monument Capital Management participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts); the ability to have advisory fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to Monument Capital Management by third party vendors. Ameritrade may also have paid for business consulting and

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professional services received by Monument Capital Management’s related persons. Some of the products and services made available by Ameritrade through the program may benefit Monument Capital Management but may not benefit its client accounts. These products or services may assist Monument Capital Management in managing and administering client accounts, including accounts not maintained at Ameritrade. Other services made available by Ameritrade are intended to help Monument Capital Management manage and further develop its business enterprise. The benefits received by Monument Capital Management or its personnel through participation in the program do not depend on the amount of brokerage transactions directed to Ameritrade. As part of its fiduciary duties to clients, Monument Capital Management endeavors at all times to economic benefits by Monument Capital Management or its related persons in and of itself creates a conflict of interest and may indirectly influence Monument Capital Management’s choice of Ameritrade for custody and brokerage services.

Best Execution

Clients are under no obligation to act on the financial planning recommendations of Monument Capital Management. If we assist in implementing any recommendations, we must seek “best execution” on behalf of the client.

While, as a fiduciary, our firm endeavors to act in its clients’ best interests, Monument Capital Management’s recommendation that clients maintain their assets in accounts at Ameritrade may be based in part on the benefit to our firm of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost, or quality of custody and brokerage services provided by Ameritrade, which may create a potential conflict of interest.

As a result of receiving such products and services for no cost, we have an incentive to continue to place client trades through broker-dealers that offer those products and services. This interest conflicts with the clients' interest of obtaining the lowest trade rate available. Therefore, we must determine in good faith, that such commissions are reasonable.

Handling Trade Errors Monument Capital Management has implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be avoided. In cases where the client causes the trade error, the client is responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client may not be able to receive any gains generated as a result of the error correction. In all situations where the client does not cause the trade error, the client is made whole and any loss resulting from the trade error is absorbed by Monument Capital Management if the error is caused by the firm. If the error is caused by the custodian, the custodian is responsible for handling the trade error. If an investment gain results from the correcting trade, the gain remains in the client’s account unless the same error involved other client account(s) that should also receive the gains. It is not permissible for all clients to retain the gain. Monument Capital Management may also confer with a client to determine if the client should forego the gain (e.g., due to tax reasons). Monument Capital Management will never benefit or profit from trade errors.

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Block Trading Policy

We may elect to purchase or sell the same securities for several clients at approximately the same time. This process is referred to as aggregating orders, batch trading or block trading and is used by our firm when we believe such action may prove advantageous to clients. If and when we aggregate client orders, allocating securities among client accounts is done on a fair and equitable basis. Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis in order to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently.

Monument Capital Management has decided to utilize the average price allocation method for transaction allocation. Under this procedure we calculate the average price and transaction charges for each transaction included in a block order and assign the average price and transaction charge to each allocated transaction executed for the client’s account.

Item 13 – Review of Accounts

Account Reviews and Reviewers

Clients contracting for modular (segmented) financial plans do not receive account reviews. Clients contracting for full plans receive on-going financial planning services for a one-year period that can include plan reviews and updates. We recommend that all clients have their financial situation reviewed and updated at least annually. Managed accounts are reviewed on an ongoing basis.

While the calendar is the main triggering factor, reviews can also be conducted at your request, a change in your financial situation, or unusual market activity or economic conditions. David Armstrong and Dean Catino are responsible for reviewing all accounts. Account reviews include checking investment strategy and objectives for a possible change in strategy and objectives.

Statements and Reports

You receive statements at least quarterly from the investment company, custodian, clearing firm or money manager where your account is maintained. Additionally, Monument Capital Management may provide performance reports to you quarterly at no additional charge. These reports should be compared against the reports received from your account custodian. You can request a report from us at any time.

Financial planning clients do not receive any report other than the plan originally contracted for.

Item 14 – Client Referrals and Other Compensation Please see Item 5 - Fees and Compensation, Item 10 - Other Financial Industry Activities and Affiliations and Item 12 - Brokerage Practices, for additional discussion concerning other

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compensation, including Monument Capital Management’s receipt of Additional Benefits as defined in Item 12 – Brokerage Practices.

Item 15 – Custody

Monument Capital Management shall have the ability to have its advisory fee for each client debited by the custodian. Clients are provided, at least quarterly, with transaction confirmation notices and regular summary account statements directly from the custodian and/or program sponsor for the client accounts. Monument Capital Management may also provide a periodic report summarizing account activity and performance.

To the extent that Monument Capital Management provides clients with periodic account statements or reports, the client is urged to compare any statement or report provided by Monument Capital Management with the account statements received from the account custodian.

The account custodian does not verify the accuracy of Monument Capital Management advisory fee calculation.

Monument Capital Management provides other services on behalf of its clients that require disclosure at ADV Part 1, Item 9. In particular, certain clients have signed asset transfer authorizations that permit the qualified custodian to rely upon instructions from Monument Capital Management to transfer client funds to “third parties.” In accordance with the guidance provided in the SEC Staff’s February 21, 2017 Investment Adviser Association No-Action Letter, the affected accounts are not subjected to an annual surprise CPA examination.

Item 16 – Investment Discretion

The client can determine to engage Monument Capital Management to provide investment advisory services on a discretionary basis. Prior to Monument Capital Management assuming discretionary authority over a client’s account, the client shall be required to execute an Investment Advisory Agreement, naming Monument Capital Management as the client’s attorney and agent in fact, granting Monument Capital Management full authority to buy, sell, or otherwise effect investment transactions involving the assets in the client’s name found in the discretionary account.

Clients who engage Monument Capital Management on a discretionary basis may, at any time, impose restrictions, in writing, on our discretionary authority. (i.e. limit the types/amounts of particular securities purchased for their account, exclude the ability to purchase securities with an inverse relationship to the market, limit or proscribe Monument Capital Management’s use of margin, etc.).

Item 17 – Voting Client Securities

Monument Capital Management does not vote proxies on your behalf. You should read through the information provided with the proxy-voting documents and make a determination based on the information provided. If requested, we may provide limited clarifications of the issues presented in

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the proxy voting materials based on our understanding of issues presented in the proxy-voting materials. However, you have the ultimate responsibility for making all proxy-voting decisions.

With respect to assets managed by any outside money manager, we do not vote the proxies associated with these assets. You need to refer to each outside money manager’s disclosure brochure to determine whether the outside money manager will vote proxies on your behalf. You may request a complete copy of sub-advisor’s proxy voting policies and procedures as well as information on how your proxies were voted by contacting Monument Capital Management at the address or phone number indicated on Page 1 of this disclosure document.

Item 18 – Financial Information

Monument Capital Management does not solicit fees of more than $1,200, per client, six months or more in advance. Monument Capital Management is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain client accounts. Monument Capital Management has not been the subject of a bankruptcy petition. Monument Capital Management’s Chief Compliance Officer, David B. Armstrong, CFA, remains available to address any questions that a client or prospective client may have regarding the above disclosures and arrangements.

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Customer Privacy Policy Notice The information contained in this section will also be disclosed in Monument Capital Management’s Privacy Policy Statement. This statement will be provided to all clients in accordance with the rules and regulations of the Gramm-Leach-Bliley Act of 1999. Commitment to Your Private Information. Monument Capital Management has a policy of protecting the confidentiality and security of information we collect about our clients. We do not, and will not, share non-public personal information (“Information”) about you with outside third parties without your consent, except for the specific purposes described below. This notice has been provided to you to describe the Information we may gather and the situations under which we may need to share it.

Why We Collect and How We Use Information. We limit the collection and use of Information within our firm to only those individuals associated or employed with us that must have Information to provide financial services to you. Such services include maintaining your accounts, processing transaction requests, and providing the advisory services described in our Form ADV. How We Gather Information. We get most Information directly from you when you provide us with information from any of the following sources:

• Applications or forms (e.g., name, address, Social Security number, birth date, assets, income, financial history)

• Transactional activity in your account (e.g., trading history and account balances) • Information services and consumer reporting sources (e.g., to verify your identity or to assess

your credit history) • Other sources with your consent (e.g., your insurance professional, attorney or accountant)

How We Protect Information. Our employees and affiliated persons are required to protect the confidentiality of Information and to comply with our stated policies. They may access Information only when there is an acceptable reason to do so, such as to service your account or provide you with financial services. Employees who violate our Privacy Policy are subject to disciplinary action, up to and including termination from employment with us. We also maintain physical, electronic and procedural safeguards to protect Information, which comply with applicable SEC, state and federal laws. Sharing Information with Other Companies Permitted Under Law. We do not disclose Information obtained in the course of our practice except as required or permitted under law. Permitted disclosures include, for instance, providing Information to unrelated third parties who need to know such Information in order to assist us with the provision of services to you. Unrelated third parties may include broker/dealers, mutual fund companies, insurance companies and the custodian with which your assets are held. In such situations, we stress the confidential nature of Information being shared.

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Former Customers. Even if we cease to provide you with financial products or services, our Privacy Policy will continue to apply to you and we will continue to treat your non-public information with strict confidentiality.

Class Action Lawsuits Client retains the right under applicable securities laws to initiate individually a lawsuit or join a class-action lawsuit against the issuer of a security that was held, purchased or sold by or for client. Monument Capital Management does not initiate such a legal proceeding on behalf of clients and does not provide legal advice to clients regarding potential causes of action against such a security issuer and whether the client should join a class-action lawsuit. Monument Capital Management recommends that you seek legal counsel prior to making a decision regarding whether to participate in such a class-action lawsuit. Moreover, our services do not include monitoring or informing clients of any potential or actual class-action lawsuits against the issuers of the securities that were held, purchased or sold by or for you.

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Business Continuity Plan Monument Capital Management has a business continuity and contingency plan in place designed to respond to significant business disruptions. These disruptions can be both internal and external. Internal disruptions will impact our ability to communicate and do business, such as a fire in the office building. External disruptions will prevent the operation of the securities markets or a number of firms, such as earthquakes, wildfires, hurricanes, terrorist attack or other wide-scale, regional disruptions.

Monument Capital Management’s continuity and contingency plan has been developed to safeguard employees’ lives and firm property, to allow a method of making financial and operational assessments, to quickly recover and resume business operations, to protect books and records, and to allow clients to continue transacting business.

The plan includes: • Alternate locations to conduct business; • Hard and electronic back-ups of records; • Alternative means of communications with employees, clients, critical business

constituents and regulators; and • Details on the advisor employee succession plan

Monument Capital Management’s business continuity and contingency plan is reviewed and updated on a regular basis to ensure that the policies in place are sufficient and operational.

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